1) May a patient be restricted for the day they are seen without the case becoming
recordable? If the restriction goes beyond the first day, is it then considered a recordable
injury?

Injuries and illnesses are not considered lost workday cases unless they affect the employee
beyond the day of injury or onset of illness. Therefore, lost workdays should not
include the day of injury or onset of illness, or any days on which the employee would not have
worked even though able to work (B-1&2, page 48). When an employee is placed on restricted
duty on the day of the injury or onset of illness and is released to return to regular work activity
the following day, the case would be recorded in column 6 or 13 of the Log as a nonfatal case
without lost workdays (C-1&2, page 52).

2) If you give a restriction and the employee is permitted to perform his job within the
limitations placed by your restriction, does that mean that the injury is not recordable?

For OSHA injury and illness recordkeeping purposes, the concept of restricted work is based on
three criteria as follow:

1. the employee was assigned to another job on a temporary basis, or
2. the employee worked at a permanent job less than full time, or
3. the employee worked at his or her permanently assigned job but could not perform all the
duties normally connected with it. (Paragraph 2, page 48).

Historically, the phrase, "employee's normal job duties" has been interpreted to include any tasks
that the employee performs or may be expected to perform throughout the calendar year. If the
"limitations" placed by the restriction apply to any of the employee's normal job duties, the case
must be recorded as one involving restricted work activity. Whether or not the employee was
scheduled to perform the duty which is restricted is not relevant in the decision making process.

If the employee would be expected to perform the activity which is restricted on any single day
during the year, the case must be recorded as one involving restricted work activity. If the
employee is never expected to perform the activity which is restricted during any one day of the
calendar year, than the case does not involve restricted work activity.

3) Does the extent of a laceration determine recordability? If a laceration is full
thickness it's recordable, even if you use steri-strips, because they are used in lieu of
sutures. On the other hand, a partial-thickness laceration that's steri-stripped can be kept
from recordability if steri-strips are not used in lieu of sutures. Is this correct?

A work related injury is recordable if it entails one or more of the following: loss of
consciousness, restriction of work or motion, transfer to another job, or medical treatment (other
than first aid) (Section A, page 28). On page 43 of the Recordkeeping Guidelines,
OSHA provides guidance for recording lacerations which entail the use of wound closures such
as sutures, butterfly adhesive dressings, and Steri-Strips (TM). The extent of the laceration does
not determine recordability. Wound closures are considered medical treatment for OSHA injury
and illness recordkeeping purposes and thus constitute a recording criteria. Steri-Strips (TM),
are always considered medical treatment for recordkeeping purposes. On the other hand, wound
coverings, such as Band-Aid bandages (TM), are always considered first aid.

I hope you find this information useful. If you have any further questions, please contact us at
Area Code: (202) 219-6463.

Sincerely,

Bob Whitmore
Chief
Division of Recordkeeping Requirements

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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